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VOC permit for bottling

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We were recently notified by NYDEC that we need a permit for bottling operations because of VOCs. I guess its because of evaporation during bottle filling. The problem is they figure the lbs of alcohol evaporation by the size of your bottler, bottle filling capacity per hour x 24/7x365. Then the annual lbs of VOCs emitted is calculated by them for our permit. Does anyone else have such a permit?

Does anyone actually have an accurate number for lbs lost during bottling for their specific bottler? 


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